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Upper Catchment Issues Vol 3 No 1

Author: Tasmanian Community Resource Auditors Incorporated

Introduction

Background and statement of the issue

For some time the local communities of Scottsdale and Bridport in Northern Tasmania (see map 1), have been concerned about the use of pesticides in the water catchments above the townships. A local Waterwatch group (Dorset Waterwatch Group Inc.), originally funded under the Commonwealth Government's Waterwatch initiative, had responded to community concerns and initiated an inquiry with a prominent forestry company, Rayonier Tasmania, who managed several forest operations in the district.

One particular site was of major concern to the local community as it was an area where water for potable use was sourced. The area known as the Upper Brid Road was the site of forestry activities on coupe SFI65A (see map 2).

In 2001, Dorset Waterwatch (DWW) contacted coupe operators Rayonier Tasmania with a number of questions regarding the use of the weedicide Velpar (hexazinone), which had leached from coupe SFI65F into a farm dam and was ultimately carried into river systems. Appendix 1 details the notes of a telephone conversation between representatives of Dorset Waterwatch and a representative of Rayonier that took place on January 29, 2001.

Dorset Waterwatch continued observations and monitoring during 2002 and 2003 and by early 2004 still had concerns over the way chemical applications were being managed in the vicinity of waterways. It was decided to conduct an ongoing inquiry based upon a Community Based Audit approach. The starting point for the audit were two letters from Dorset Waterwatch to Rayonier (see Appendices 2 and 3) detailing concerns over management practices and observations of chemical overspray of an open waterway in coupe SF165A. Rayonier's replies are included in Appendices 2 and 3.

Methodology and Methods of Inquiry

The overall approach to the inquiry was guided by the emerging tradition of Post Normal Science, where the public is seen as an important source of not only "data", but valid and relevant knowledge (Harding (ed) 1998).

A form of action research was used as the overarching methodology (Stringer 1996; Gschwendtner et al n.d.). Action research was the favoured approach as it provided a disciplined and iterative cycle of "plan-act-reflect", which was thought to be essential in a process of deepening inquiry. The key methods used were structured and semi-structured interview (Fontana and Frey 1994).

Results and Discussion

The process of inquiry had been ongoing for a period of nearly 4 years. This culminated in a meeting with Rayonier Tasmania arranged by Dorset Waterwatch on September 2, 2004, where a series of questions were asked of Rayonier Tasmania representatives during a semi-structured interview session.

Of particular concern to Dorset Waterwatch was the confirmation by Rayonier Tasmania representatives that herbicide overspray of a waterway had occurred, and that no follow up water sampling had been conducted. This was in spite of a written undertaking from the company to Dorset Council in 2001 to conduct water sampling for all agricultural chemicals where products are applied aerially (Appendix 4).

The record of that meeting is found in Appendix 5 and includes a list of specific follow up questions relating to water sampling and testing for pesticide run off in relation to Rayonier Tasmania's failure to conduct water sampling in conjunction with the spray operation on coupe SF165A.

The record states:

"One of the reasons given for not testing was a recurring irregularity with test results. CR (Rayonier Tasmania) reported that the NATA registered lab used by Rayonier found traces of chemicals in water samples collected prior to spraying at various sites across Tasmania. This had called into question the validity of test results, and therefore, testing was discontinued. PC (Rayonier Tasmania) agreed to provide the name of the lab. Rayonier had not sourced another lab as the one used was the only NATA registered lab vailable."

The record goes on to state:

"PH (Dorset Council) asked how long the NATA lab was off-line for? CR replied that according to recent reports by Forestry Tasmania the problem with the irregular test result had been fixed."

At this point it appeared to Dorset Waterwatch that Rayonier representatives were alleging that the irregular test results, which prompted suspension of water sampling, were a result of problems with laboratory procedures. No other possible sources of water sample contamination were discussed at the meeting (see scribe notes, Appendix 6).

Rayonier responded to the Dorset Waterwatch follow-up questions with a letter dated October 4, 2004 (Appendix 7). The letter confirms suspension of Rayonier Tasmania's water sampling program due to "irregular results" which called into question the integrity of the testing process, but states that the suspension was in early 2003, justified by a review of sample results from 2002 which showed no detects in any of the areas sprayed in Dorset.

The comments made by Rayonier representatives at the meeting of September 2004 regarding the company's water sampling program (see Appendix 5, first two dot points on page 31) are at odds with the written reply by Peter Clayton of Rayonier in his letter dated October 10, 2004 (Appendix 7).

If, in fact, water sampling had resumed in 2004, test results for Coupe SFI65A (sprayed on March 18, 2004) should have been available. All previous discussions and correspondence reveal that no such results existed, meaning that water sampling and testing were not done for whatever reason.

In any case, DWW acknowledges the number of positive commitments made by Peter Clayton, particularly those relating to the formal documentation of water sampling protocols in Rayonier's EMS, and several specific improvements to the ongoing management of Coupe SF 165A, and hopefully other coupes in the future.

Dorset Waterwatch still remained concerned that a number of questions (see Appendix 5) remained to be answered, accordingly an emailed request was sent and is shown in Appendix 8. In the response dated November 15, 2004 (see Appendix 9), Rayonier did not answer the outstanding questions but undertook to complete certain tasks as per their letter of October 4, 2004, (Appendix 7).

In the meantime, Dorset Waterwatch initiated an inquiry into the issue of "irregular results" for water testing which Rayonier representatives had alleged was the reason for a suspension of Rayonier's water sampling program for a period of time. The inquiry involved discussion with the manager of the laboratory who provided the analysis service (Analytical Services Tasmania) followed up with a letter of inquiry from Dorset Waterwatch (see Appendix 10). The reply from the laboratory manager is found in Appendix 11. In it he offers possible explanations for the detection of hexazinone in pre-spray samples none of which, in his opinion, could have originated in laboratory procedures.

It was clear from the audit trail that there were serious mismatches between what Dorset Waterwatch understood Rayonier Tasmania to be saying had happened, when it had happened, and the laboratory manager's account of the developing situation. In an effort to resolve the apparent anomalies Dorset Waterwatch wrote to Rayonier Tasmania (see Appendix 12) to offer an opportunity to clarify matters prior to the publication of this audit.

Rayonier Tasmania responded by calling a meeting on January 31, 2005 (see Appendix 13). At the meeting, Rayonier Tasmania offered the explanation that a misunderstanding had occurred between the two parties. He explained that at the on-site meeting of September 2, 2004, in regards to the cause of the suspension of its water sampling program, Rayonier Tasmania staff had been referring to possible faults within the water testing process, not the laboratory, as reported in the record of the meeting.

The following is an excerpt from the record of the January 31, 2005 meeting (see Appendix 13):

"KE (DWW) noted that Rayonier had opportunity to correct the DWW record of the meeting (recorded by three scribes) if they felt it was inaccurate, but failed to do so. MC (Rayonier Tasmania) agreed that Rayonier should have stated their concerns with the record at the time. KE pointed out that Rayonier representatives had not mentioned any internal inquiry into sampling processes at the meeting. She explained that Rayonier representatives had also stated that this was not the first time that irregular results had been obtained and that there had not been an adequate explanation from the laboratory for the results. MC stated that he had no knowledge of this."

As a follow up to this meeting, Rayonier sent a letter to Dorset Waterwatch (see Appendix 14) providing answers to Dorset Waterwatch's outstanding questions. The letter states that suspension of Rayonier Tasmania's water sampling program occurred in February to March 2004. It also explains that the Corrective Action Response, (CAR) generated under Rayonier Tasmania's Environmental Management System to deal with the chemical overspray of a waterway in coupe SF165A, was instigated only after Dorset Waterwatch brought the matter to their attention.

The audit trail has led Dorset Waterwatch to question the integrity of the testing protocols used by Rayonier Tasmania and therefore the validity of any risk assessment process based upon it. It would appear that only through the diligence of Dorset Waterwatch was the overspray of a town water supply tributary picked up and resultant corrective actions instigated. This backs up long held concerns by Dorset Waterwatch that current risk assessment, in relation to the application of chemicals, may be inadequate to ensure that chemicals are contained to the site.

It further brings to light the importance of continued diligence and inquiry by the community in highlighting areas where current practices are failing to meet industry and community expectations of best practice, in an effort to contribute positively to change.

Conclusions and Recommendations

During the course of the investigation it was confirmed by Rayonier representatives that overspray of a waterway feeding two town water supplies had occurred as a result of unpredictable wind conditions during an aerial spray application of herbicide.

It was also confirmed that no water sampling of the waterway had been conducted subsequent to the spray operation, in spite of a written undertaking to Dorset Council in 2001. Rayonier representatives alleged there had been a series of irregular water sample results for the herbicide Velpar, showing chemical contamination of water samples prior to spraying, in samples analysed by Analytical Services Laboratory Tasmania, (AST).

Stringent laboratory procedures and protocols for minimising the risk of cross contamination of samples and an impeccable track record of quality control are outlined by AST's manager in his letter to Dorset Waterwatch. Thus it would appear that irregular sample results may stem from other factors. The laboratory manager's letter highlights several starting points for further investigation into possible avenues of cross contamination in the field, including the storage and transportation of sample bottles and the training of personnel collecting samples.

As well, the laboratory manager suggests that what Rayonier representatives described as a "irregular results" of Velpar in water samples taken by the company in 2004 may possibly have been actual contamination of the water by upstream spray operations or ingress of groundwater contaminated by spray operations off site.

These findings lead to the following recommendations:

1.) That Rayonier immediately conduct in depth risk assessment of its operational procedures in regards to mitigating/eliminating contamination risks to riparian areas and groundwater supplies within coupes under its management.

2.) That Rayonier engage the services of other NATA accredited laboratories in cross checking irregular water samples, to allay doubt regarding the source of contamination, rather than suspend future water sampling programs for any period of time.

3.) That Rayonier evaluate current methods of storage and transportation of water sampling paraphernalia to ensure that current practices are not contributing to cross contamination of samples

4.) That Rayonier ensure all personnel are appropriately trained to conduct water sampling with a view to eliminating possible cross contamination of samples.

5.) That Rayonier conduct downstream water sampling and groundwater sampling to determine if sprays applied during operations conducted by the company are contained to site.



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